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Is a pre-election hearing required under Section 9(c) in all cases regardless of whether material facts are in dispute?

A pre-election hearing is required in all cases where the parties have not entered into an election agreement, but a full scale “evidentiary hearing” is not required in every case, only “an appropriate hearing.” There may be times when there are no disputes which must be resolved and, therefore, an appropriate hearing does not require the introduction of extensive evidence.